Checklist to File ACA Application for TCC

Affordable Care Act (ACA) required reporting is right around
the corner. In order to e-file ACA information returns with the IRS, you need
to obtain a Transmitter Control Code (TCC). Gather and check off the items you
need to complete required fields on the ACA Application for TCC.

The checklist below is based on the new version of an IRS tutorial and expands on step 3 in my post on the ACA Information Returns (AIR) system. But first, let me provide some background information.

What is the purpose of a TCC?

E-filing is required for providers of minimum essential coverage that file 250 or more information returns during the calendar year. The purpose of the TCC application is to receive a TCC to become authorized to e-file Forms 1094B, 1095-B, 1094-C and 1095-C.

Does
your organization need to designate Responsible Officials?

If your organization performs any of the following roles, you must designate Responsible Officials to complete the application.

Issuer: An organization
that files its own ACA information returns

Transmitter: A third
party that sends electronic information return data directly to the IRS on
behalf of any business

Software Developer: An
organization that writes origination or transmission software according to IRS
specifications. (The software developer role and duties are outside the scope
of this blog.)

The roles are not mutually exclusive.

What
is the application process?

Identify the Responsible Officials and Contacts. All Responsible Officials and Contacts need to be registered and confirmed with IRS e-Services before the application can be submitted. Each Responsible Official (minimum of two required) and Contact (minimum of two required) within the organization must complete the e-Services “Secure Access Authentication” process before the application can be submitted. Responsible Officials may also be Contacts on the application.

Access the TCC application in IRS e-Services and start filling it out. All Responsible Officials must sign the Application Submission Page with their e-Services PIN to submit the application. Note: Responsible Officials may go to the Modify PIN tab to recover their e-Services PIN.

After the application is submitted and processed, the IRS will
assign a TCC for each role selected on the application. TCCs are sent to you
via U.S. Postal Service and appear on the summary screen of your completed,
processed application. The typical application will be processed within seven
business days.

Who should apply for a TCC?

Section 2 of IRS Publication 5165 explains
who should apply for TCC, emphasizing, “If you are an employer or insurance
issuer/carrier using a 3rd party to prepare and transmit your information
returns to the IRS, you do
not need to obtain a TCC.”

Confused about the TCC roles? IRS Publication 5165 includes a table titled “What roles should I select on my ACA Application for Transmitter Control Code?” containing if-then scenarios. See Table 2-1 on page 11 as of March 2019.

Checklist of information required to apply for TCC

Firm information

Employer identification number (EIN)

Legal name

Doing-business-as name (if different than legal name)

Business type (select from a drop-down list)

Phone number

Mailing address (PO Box is acceptable)

Business address if different from mailing address (PO Box is not acceptable)

Responsible Officials information

Note: A Responsible Official can also be a Contact. You are required to enter at least two Responsible Officials.

Name

Position or title (select from a drop-down list)

U.S. citizen

Social Security number or individual tax ID number

Date of birth

E-mail address

Phone number

Determine if this person will also be a Contact

Contacts information

Note: Contacts should be available on a daily basis to answer IRS questions. You are required to enter at least two people.

Transmission method for each of the forms you will be submittingNote: The electronic format of ACA information returns is Extensible Markup Language (XML), a language that specifies the structure and content of electronic documents and files.

ISS-A2A System Enroller: This option involves a machine-to-machine process to send a Simple Object Access Protocol (SOAP) message. The information return data is sent in XML structured data files as an attachment to the SOAP message.

ISS-UI for ACA Internet Transmitter: This option involves using an internet browser to browse for and upload the respective information return as an XML file.

For the different types of TCC are there certain entities that may need multiple codes? For example if you are an ALE transmitting on your own behalf but also transmitting on behalf of other groups as their TPA? In this case would you transmit as an issuer for yourself and transmitter to transmit for others or would simply registering as a transmitter suffice both? Thanks!

Yes, the ACA TCC is different. Forms W-2/W-3 are electronically filed with the Social Security Administration through SSA’s Business Services Online (BSO). You can find more about BSO at https://www.ssa.gov/employer/. BSO is separate from the AIR system.

We have multiple companies but would fall under the Large Employer Member (ALE Memeber) when transmitting the 1094-C. On this form I see we can list all ALE Member information with their EIN numbers since they are part of the Aggregated ALE Group but do I need to apply for separate TCC numbers for each of our companies?

There are three defined roles to apply for a TCC – Responsible Official, Contact and Software Developer. On all of the documentation I have found it is required that there be at least one Responsible Official and two Contacts, but no where can I find that a Software Developer is mandatory.

No, selecting the Software Developer role is not mandatory. In the “Application Details” section of the TCC application you have to select at least one role and you can select more than one. You can select any combination of roles. Each role selected on the application results in a separate TCC.

I applied to be both an issuer(for our company) and transmitter (for 4 of our subsidiaries). I received two separate TCC codes. However, none of the subsidiary names are listed anywhere (I was not asked to provided during the application process) and so now I don’t know how to add them so I can start submitting for them. TIA!

I noticed a similar, but not exact, Q&A was addressed in the ACA AIR Working Group Meeting on June 14, 2016.

“Question #9: Does each Applicable Large Employer (ALE) member of an Aggregated ALE group need to have their own TCC code (each ALE member having their own EIN) for electronic submission? IRS Response #9: TCCs are assigned by EIN. If each ALE group is going to transmit their own return, then each group will need their own TCC code.”